# France - Estonia tax treaty Your Estonian OÜ while you live in France. How the France - Estonia double tax treaty, French law and Estonian law apply to a French resident who owns an Estonian OÜ: residence, place of management, permanent establishment, board fees, dividends, the French CFC rule, article 155 A, exit tax and more. Law as of 1 Oct 2026. General information, not advice for your situation. You live in France and own an Estonian OÜ, or plan to found one. This page shows how the Estonia - France tax treaty splits the right to tax between the two countries, and what French and Estonian law add. The treaty has no authentic English text, so this page paraphrases it: only the French and Estonian texts in the facts box bind. French law changes often and depends on your facts, so confirm each French point with a French tax adviser before you act. ## Treaty facts | | | | ------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | Treaty | Convention between the Government of the Republic of Estonia and the Government of the French Republic for the avoidance of double taxation and the prevention of tax evasion and fraud with respect to taxes on income and on capital, with a Protocol ([Riigi Teataja](https://www.riigiteataja.ee/akt/78860), [French text](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_convention-avec-l-estonie_fd_1428.pdf)). The English name is an unofficial translation | | Signed | 28.10.1997 in Paris, with a Protocol of the same date | | In force | 01.05.2001 | | Effective from | 01.01.1996, retroactively: taxes withheld at source on income received from that date, other taxes on income for tax years beginning on or after it | | Protocols | Protocol of 28.10.1997 (part of the treaty). Its points 9 (interest) and 10 (royalties) are most-favoured-nation clauses: point 9 was triggered from 21.05.2006 and again from 11.12.2015, point 10 from 11.12.2015 ([Ministry of Finance](https://www.fin.ee/en/public-finances-and-taxes/tax-and-customs-policy/overview-estonian-bilateral-conventions-avoidance); French [consolidated version](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_version_consolidee_npf.pdf), not authentic). No amending protocol | | MLI | A Covered Tax Agreement for both states (Estonia's agreement 16, France's agreement 30), but **not in effect**. The MLI is in force for France from 01.01.2019 and for Estonia from 01.05.2021, and Estonia has not yet sent the notification under MLI Art. 35(7)(b) for France ([OECD status list](https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf), 15.09.2026). Once in effect, it would apply MLI Art. 6(1) (preamble), 7(1) (principal purpose test), 9(4) (replacing Art. 13(1)(b)) and 16 (replacing the first sentence of Art. 25(1)). No synthesised text exists | | Authentic languages | French and Estonian, equally authentic. Neither prevails, and there is no authentic English text. Article numbers on this page follow the French text: in Art. 23, paragraph 1 is the French method and paragraph 2 the Estonian method | ## In short - e-Residency and an Estonian OÜ do not make you resident in Estonia. If you live in France, France taxes your worldwide income. - If you run the OÜ from France, France can tax it through a permanent establishment, and possibly as a French resident company. The treaty has no fixed tie-breaker for companies. - Estonia taxes your board member fee, but the two authentic texts of the board fee article differ, so the French credit is not certain. A salary for work you do in France is taxed only in France. - Estonia withholds no tax from your dividend. France taxes it at 12.8 percent plus 18.6 percent social contributions in 2026, and you cannot credit the Estonian 22/78 company tax. - France has extra tools against a one-person OÜ: the reattribution of fees under article 155 A, the CFC rule of article 123 bis and the 80 percent penalty for an undeclared activity. - If you leave France, French exit tax can apply to your OÜ shares, deferred for a move to Estonia. ## Does e-Residency or an Estonian company make me tax resident in Estonia? No. You are resident in Estonia only if you have your place of residence there or stay there at least 183 days in 12 consecutive months ([TuMS § 6 lg 1](https://www.riigiteataja.ee/akt/129042026004)). e-Residency and company ownership count for neither ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). The Estonian side is explained in our guide on [founder residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc). France treats you as domiciled in France if you meet any one of three tests: your home or main place of stay is in France, you work in France and that work is not merely accessory, or the centre of your economic interests is in France ([CGI art. 4 B, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051202565)). A French tax domicile means French tax on your worldwide income ([CGI art. 4 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000006302200)). The tests are alternatives, so an owner who has moved to Estonia but still runs the OÜ's main business from France can stay domiciled in France. If both countries treat you as resident, the treaty decides in this order: permanent home, centre of vital interests, habitual abode, nationality, and finally agreement between the two tax authorities (Art. 4(2) of the treaty). The treaty has no rule for splitting the year of a move. The MLI does not change this article. Confirm with a local adviser: how France fixes the date of departure in the year you move, which French return you file for that year, and whether your OÜ shares and their income keep the centre of your economic interests in France. ## Can France treat my Estonian company as a French company? Possibly. Estonia always treats the OÜ as resident, because it was founded under Estonian law ([TuMS § 6 lg 2](https://www.riigiteataja.ee/akt/129042026004)). The treaty also lets France claim it as resident if French law taxes it because its place of management (siège de direction) is in France (Art. 4(1)(a) of the treaty). French corporate tax is territorial: it reaches the profits of businesses carried on in France ([CGI art. 209, I](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048847486)). So France has two routes to a one-person OÜ run from a French home: as a resident company, or as a business with a permanent establishment in France (Art. 5(2)(a) and 7(1); see [below](https://oscaraccountant.com/en/tax-treaties/france#does-my-work-from-home-in-france-create-a-permanent-establishment)). If both countries claim the company, there is no automatic tie-breaker. The two tax authorities try to agree, and they weigh the place of effective management, the registered office, the place of incorporation and any other relevant factor. Without an agreement, the company is not resident of either state for the benefits of the treaty (Art. 4(3)). It then cannot rely on the treaty limits on dividends, interest and royalties, or on the protection of Art. 7(1). The MLI does not change Art. 4(3), because both states reserved MLI Art. 4. EMTA confirms: "income of Estonian companies is also taxed abroad" when they are managed outside Estonia ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). Confirm with a local adviser: whether French law makes a foreign company whose real seat or effective management is in France liable to corporate tax because of that seat, or only on the business carried on in France. Ask also for how many past years France can reassess (see [below](https://oscaraccountant.com/en/tax-treaties/france#what-if-i-never-registered-the-activity-in-france)). ## What does France look at to decide where my company is managed? The treaty names the criteria but does not define them. In practice the question is where the key management decisions are really taken, and for a sole board member living in France that is usually France. A place of management in France is also a permanent establishment (Art. 5(2)(a) of the treaty). Estonian law requires no management in Estonia: the OÜ is resident by incorporation ([TuMS § 6 lg 2](https://www.riigiteataja.ee/akt/129042026004)), and its management board manages and represents it ([ÄS § 180 lg 1](https://www.riigiteataja.ee/akt/106072023131)). A registered address, a contact person and an Estonian accountant do not move management to Estonia. The facts that can: - an Estonian board member who actually decides; - board meetings held in Estonia, with the owner present; - staff and contracts run from Estonia; - real working time of the owner in Estonia. Paper meetings with every decision taken from France do not. Electronic signatures leave a record of where and when each document was signed. Keep a file that shows where each decision was made, every year. The Estonian evidence list is in our guide on [founder residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc). Confirm with a local adviser: which facts the French tax administration's commentary (BOFiP) and French case law use for the place of effective management of a foreign company, and whether there is case law on a single-shareholder company managed from the owner's French home. ## Does my work from home in France create a permanent establishment? Often yes. A permanent establishment is a fixed place of business through which the OÜ carries on its business, and the list of examples includes a place of management (Art. 5(1) and 5(2)(a) of the treaty). A home in France from which you run the OÜ usually meets both. A person who habitually uses in France an authority to conclude contracts in the OÜ's name also creates one (Art. 5(5)). An employee in France who only does the work, without that authority, does not create one under Art. 5(5). The MLI would not widen these rules, because Estonia reserved MLI Art. 12 to 15. France can then tax the profit the permanent establishment would earn as a separate enterprise at arm's length (Art. 7(1) and (2); Protocol of 28.10.1997, point 4). When you do all the work in France, that can be most of the OÜ's profit. The normal French corporate tax rate is 25 percent ([CGI art. 219, I](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542939)). On the Estonian side, a dividend paid out of the profit of a permanent establishment in an EEA state bears no Estonian distribution tax ([TuMS § 50 lg 1^1 p 2](https://www.riigiteataja.ee/akt/129042026004)). This domestic rule is more favourable than the treaty credit, and the treaty lets it prevail (Art. 23(2)(a)). EMTA confirms that a permanent establishment abroad is taxed under the applicable treaty ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). Confirm with a local adviser: how the permanent establishment registers and files in France, whether the reduced 15 percent rate of CGI art. 219 can apply to it, whether France charges a branch profits tax given Art. 10(7) of the treaty, and how France reads the 2025 OECD guidance on home offices. ## How is my board member fee taxed? Estonia taxes the fee: the OÜ withholds 22 percent income tax ([TuMS § 29 lg 2, § 41 p 2, § 4 lg 1](https://www.riigiteataja.ee/akt/129042026004)). It also pays 33 percent social tax, unless you hold a valid A1 certificate from France ([SMS § 2 lg 1 p 4](https://www.riigiteataja.ee/akt/121052026019); [EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). As a resident of an EEA state, you can claim the Estonian basic exemption at source ([TuMS § 42 lg 1](https://www.riigiteataja.ee/akt/129042026004)). The treaty allows Estonia to tax directors' fees (Art. 16 of the treaty), but the two authentic texts differ. The Estonian text names fees received as a member of the management board, which is the board of an OÜ. The French text names fees received as a member of the board of directors or the supervisory board, which an OÜ does not have. France taxes the fee as part of your worldwide income ([CGI art. 4 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000006302200)). For income under Art. 16, France gives a credit equal to the Estonian tax you paid, capped at the French tax on that fee (Art. 23(1)(a)(ii)). If France reads Art. 16 as not covering an OÜ board member, the fee falls under another article: work done in France would then be taxable only in France, and the 22 percent withheld in Estonia would not be creditable. The tool to settle such a conflict is the mutual agreement procedure (Art. 25(3); see [below](https://oscaraccountant.com/en/tax-treaties/france#what-can-i-do-if-both-countries-tax-the-same-income)). Confirm with a local adviser: whether the French administration accepts that Art. 16 covers an OÜ management board member, in which French income category you declare the fee, and on which form you claim the credit. More on the Estonian side: [founder remuneration](https://oscaraccountant.com/en/guides/founder-remuneration). ## Where is a salary for work I do in France taxed? Only in France. A salary for work done in France by a French resident is taxable only in France (Art. 15(1) of the treaty). Estonia taxes a non-resident's salary only for work done in Estonia ([TuMS § 29 lg 1](https://www.riigiteataja.ee/akt/129042026004)), and charges no social tax on pay for work done abroad ([SMS § 3 p 7](https://www.riigiteataja.ee/akt/121052026019)). Days you work in Estonia are different. The 183-day exception does not protect you, because your employer, the OÜ, is an Estonian resident (Art. 15(2)(b)). Estonia may tax those days, and France gives a credit equal to the French tax on that part (Art. 23(1)(a)(i)). Keep a log of the days you work in Estonia. The Estonian rules for cross-border workers are in our guide on [contractors and cross-border workers](https://oscaraccountant.com/en/guides/contractors-and-cross-border-workers). A board member fee follows Art. 16 instead (see the section above). A salary for work in France can also point to a permanent establishment of the OÜ in France. Confirm with a local adviser: what a foreign employer with no French establishment must do for French payroll (withholding at source, registration). ## Which social security applies to me, and can URSSAF claim contributions? The tax treaty does not decide this. It covers taxes on income and on capital, and lists no social contribution (Art. 2 of the treaty). The EU coordination rules ([Regulation (EC) No 883/2004](https://eur-lex.europa.eu/eli/reg/2004/883/oj) and [Regulation (EC) No 987/2009](https://eur-lex.europa.eu/eli/reg/2009/987/oj)) apply the law of one state only, and the institution of your state of residence decides which ([CLEISS](https://www.cleiss.fr/independants/etranger_france883.php?from=estonie&nat=france)). If you live in France and do most of the work for the OÜ there, you are normally insured in France, so French contributions can be claimed on that activity. In Estonia, a salary the OÜ pays you for work done in France bears no social tax at all, with or without an A1 ([SMS § 3 p 7](https://www.riigiteataja.ee/akt/121052026019)). Only the board fee needs the A1: without it, the OÜ pays 33 percent social tax on the fee ([SMS § 2 lg 1 p 4](https://www.riigiteataja.ee/akt/121052026019)), and France may claim its own contributions as well. EMTA accepts a valid A1 of your home country as the proof ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). The Estonian A1 for a temporary activity in France lasts at most 24 months and fits a real posting, not an owner who lives in France and runs the OÜ from there ([CLEISS](https://www.cleiss.fr/independants/etranger_france883.php?from=estonie&nat=france)). You can keep a French micro-entreprise next to the OÜ, but both activities then count for the one-state rule. Keep the two activities separate, with different clients and services. Confirm with a local adviser or URSSAF: whether your work for the OÜ counts as self-employed (TNS) or salaried activity in France, which body issues your A1, from which date contributions are due, and the micro-entreprise ceilings and rules on combining activities. ## How does France tax a dividend from my company? France taxes the dividend (Art. 10(1) of the treaty). The default is the flat income tax rate of 12.8 percent ([CGI art. 200 A, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546896)), plus social contributions of 18.6 percent in 2026, against 17.2 percent for 2025 ([service-public.gouv.fr](https://www.service-public.gouv.fr/particuliers/vosdroits/F2329)). That is 31.4 percent in total. By an overall option in your return you can choose the progressive scale instead ([CGI art. 200 A, 2](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546896)). Only with that option is the dividend reduced by 40 percent ([CGI art. 158, 3, 2°](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373673)). In the year you receive the dividend, a non-final advance payment of 12.8 percent is due. When the payer is abroad, you pay it yourself, and it is credited against the final tax. A person whose reference tax income of the year before last was below 50,000 euros (single) or 75,000 euros (couple filing jointly) can ask in advance to be exempted ([CGI art. 117 quater](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000036428175)). Estonia withholds nothing from a dividend paid to you. The only Estonian tax is the OÜ's 22/78 on the distribution ([TuMS § 41, § 50 lg 1, § 4 lg 1](https://www.riigiteataja.ee/akt/129042026004)). EMTA confirms that "no further income tax withholding will apply" ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). The treaty would let Estonia tax the dividend at up to 15 percent (Art. 10(2)(b)), but Estonian law does not use that right. See [how the distribution tax works](https://oscaraccountant.com/en/guides/cit-distribution-tax), [how to pay a dividend](https://oscaraccountant.com/en/guides/dividends-mechanics) and the [dividend tax calculator](https://oscaraccountant.com/en/tools/dividend-tax-calculator). Confirm with a local adviser: on which forms and by which dates you declare the foreign dividend and the advance payment, and the deadline of the exemption request. ## Can I credit the Estonian 22/78 company tax against my French tax? In general, no. For a dividend, France credits the Estonian tax paid under the dividend article (Art. 23(1)(a)(ii) of the treaty), and only the Estonian tax actually and finally borne by the French resident who is taxed on the dividend (Art. 23(1)(c)(ii)). The 22/78 is the OÜ's own tax ([TuMS § 50 lg 1](https://www.riigiteataja.ee/akt/129042026004)), and the dividend article leaves the taxation of the company unaffected (Art. 10(2)). EMTA says the same: the company tax is usually not creditable abroad because "the Estonian income tax was paid by a different person" ([EMTA](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies)). The treaty rates of 5 and 15 percent cap Estonian tax on the shareholder. Estonia charges none, so the rates give you nothing to credit. The 5 percent rate is only for a company shareholder in any case (Art. 10(2)(a)). Your total cost is the 22/78 in Estonia plus the French tax on the net dividend. With the progressive scale option, the 40 percent allowance partly makes up for the company tax ([CGI art. 158, 3, 2°](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373673)). Under the default 12.8 percent rate it does not apply. Confirm with a local adviser whether French law or the BOFiP commentary on this treaty gives an individual any relief for the Estonian distribution tax. ## What if my company lends me money or pays my private costs? In Estonia, the OÜ pays 22/78 on a loan to a shareholder that is in substance a hidden distribution ([TuMS § 50^2](https://www.riigiteataja.ee/akt/129042026004)), on a private expense paid for you ([TuMS § 51](https://www.riigiteataja.ee/akt/129042026004)), and on a fringe benefit given to you as board member ([TuMS § 48](https://www.riigiteataja.ee/akt/129042026004)), plus 33 percent social tax on the fringe benefit ([SMS § 2 lg 1 p 7](https://www.riigiteataja.ee/akt/121052026019)). The treaty classifies each item by its nature: - What Estonia taxes as a distribution is a dividend for the treaty (Art. 10(5) of the treaty), so France may tax it (Art. 10(1)). - A benefit for your work is pay: board fees under Art. 16, salary under Art. 15. A dividend does not include income under Art. 16 (Art. 10(5)). - Anything else is other income, taxable only in France (Art. 21(1)(a)). - If the loan is genuine, interest you pay the OÜ falls under Art. 11, and a non-market rate can be corrected (Art. 9 and 11(7)). For a French company, French law treats sums made available to its shareholders as advances or loans as distributed income ([CGI art. 111 a](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000043662702)), and such sums do not get the 40 percent allowance ([CGI art. 158, 3, 3° d](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373673)). A loan from the OÜ to you needs a written agreement, a market interest rate and real repayment ([TuMS § 50 lg 4](https://www.riigiteataja.ee/akt/129042026004)). Confirm with a local adviser: whether France applies art. 111 a, or a similar rule, to a loan from a foreign company to a French-resident shareholder, and how France taxes a private expense or a benefit paid by the OÜ. ## How is interest between France and my company taxed? The lender's state of residence taxes the interest (Art. 11(1) of the treaty). The source state may tax up to 10 percent of the gross amount (Art. 11(2)). Some interest is taxable only in the residence state, for example trade credit between unrelated enterprises (Art. 11(3)). Under the most-favoured-nation clause, interest on a loan of any kind granted by a credit institution is also taxable only in the residence state (Protocol, point 9; see [below](https://oscaraccountant.com/en/tax-treaties/france#what-did-the-most-favoured-nation-clause-change-in-2015)). In practice neither state withholds on ordinary loan interest. Estonia taxes a non-resident's interest only from certain real estate funds ([TuMS § 29 lg 7](https://www.riigiteataja.ee/akt/129042026004)). France's 75 percent levy reaches only interest paid in a non-cooperative state or territory ([CGI art. 125 A, III](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037526745)). If you lend to the OÜ, the interest is your French income, taxed at the flat 12.8 percent or on the scale, plus social contributions ([CGI art. 200 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546896)). If the OÜ lends to a French company of the group, the interest is part of its profit, taxed in Estonia only on distribution. The safe rate is an arm's-length rate. The treaty limits apply only to an arm's-length amount (Art. 11(7)), and Estonia taxes excess interest paid to a related person at 22/78 ([TuMS § 50 lg 4](https://www.riigiteataja.ee/akt/129042026004)). The treaty keeps France's thin capitalisation rules (Protocol, point 13). Confirm with a local adviser: whether the French advance levy applies to interest you receive from the OÜ, the current French limit on interest deducted by a French company to a related lender, whether the French anti-hybrid rules apply when the OÜ pays no tax until it distributes, and the current list of non-cooperative states. ## Does France withhold tax on royalties or service fees paid to my company? French law withholds tax at the corporate tax rate, 25 percent, on several payments to a non-resident with no French establishment: fees for professional activities in France, payments for intellectual property and payments for services provided or used in France ([CGI art. 182 B](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000045765660), [CGI art. 219](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542939)). The treaty overrides this for an Estonian resident: - **Service fees** are business profits. France may tax them only through a permanent establishment of the OÜ in France (Art. 7(1) of the treaty). - **Royalties** may be taxed at source at up to 5 percent (equipment) or 10 percent (other) under the treaty text (Art. 12(2)). Since 11.12.2015, the most-favoured-nation clause makes them taxable only in the state of residence of the beneficial owner, and equipment rental is no longer a royalty (Protocol, point 10; [Ministry of Finance](https://www.fin.ee/en/public-finances-and-taxes/tax-and-customs-policy/overview-estonian-bilateral-conventions-avoidance); [French consolidated version](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_version_consolidee_npf.pdf)). For the treaty benefits on royalties, the OÜ presents a certificate of residence form certified by the Estonian tax authority (Protocol, point 14(b)). If your OÜ pays royalties to France, it withholds 10 percent under Estonian law ([TuMS § 29 lg 6 p 4, § 41 p 8, § 43 lg 1 p 2](https://www.riigiteataja.ee/akt/129042026004)). With the French recipient's residence certificate filed with the TSD, the rate is nil from 11.12.2015 ([TuMS § 43 lg 2](https://www.riigiteataja.ee/akt/129042026004)). Estonia taxes service fees only for services provided in Estonia ([TuMS § 29 lg 3](https://www.riigiteataja.ee/akt/129042026004)). Confirm with a local adviser: which French form stops the art. 182 B withholding on fees for an Estonian company, or obtains a refund, and whether the French payer applies the residence-only royalty rule without further formality. ## What if my company owns a French company? French law withholds 25 percent on dividends paid to a foreign company ([CGI art. 119 bis, 2](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051218411), [CGI art. 187, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051218440)). The relief: - 0 percent under the French rule for EU parent companies, with a direct holding of at least 10 percent kept for two years or a commitment to keep it, and other conditions ([CGI art. 119 ter](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000031815505)). It does not apply to an arrangement that is not genuine and has a tax advantage as a main purpose (art. 119 ter, 3); - else 5 percent under the treaty, if the OÜ holds directly or indirectly at least 10 percent of the French company's capital (Art. 10(2)(a)(ii) of the treaty); - else 15 percent (Art. 10(2)(b)). In Estonia, with at least 10 percent at receipt, the OÜ can pass the French dividend on without Estonian income tax ([TuMS § 50 lg 1^1 p 1](https://www.riigiteataja.ee/akt/129042026004)), if the French company could not deduct the dividend ([TuMS § 50 lg 1^3](https://www.riigiteataja.ee/akt/129042026004)). Below 10 percent, the OÜ pays 22/78 when it distributes and deducts the French tax withheld, up to the amount the treaty allows ([TuMS § 54 lg 5](https://www.riigiteataja.ee/akt/129042026004)). If you live in France, you then pay French tax on the dividend you receive. Keep the evidence of the holding percentage on the payment date and of the French tax paid. EMTA can ask for it years later. Confirm with a local adviser: the version of CGI art. 119 ter in force from 01.01.2027, which was not read, and which form the French company needs to apply the exemption or the 5 percent rate at source. ## Can my Estonian holding own French property through a French SAS? Yes, but France taxes the property at every level. The SAS pays French corporation tax on the rent and on a sale of the property (Art. 6 and 13(1)(a) of the treaty give France that right). Its dividends to the Estonian holding bear the French withholding, reduced to 5 percent by the treaty for a holding of at least 10 percent (Art. 10(2)(a)(ii)), or exempt under [CGI art. 119 ter](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000031815505) unless its anti-abuse clause applies. A holding with a single French asset is the usual target of that clause. A sale of the SAS shares may be taxed in France if its assets consist principally of French property, because French law treats that gain like a property gain (Art. 13(1)(b); [CGI art. 244 bis A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806274)), at the corporate rate for a company seller. The transfer also bears a 5 percent registration duty ([CGI art. 726](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048845731)). The treaty keeps France's thin capitalisation rules for the holding's loan to the SAS (Protocol, point 13), and the interest may be taxed in France at up to 10 percent (Art. 11(2)). In Estonia, the holding can pass a dividend from the SAS on without the 22/78 if it held at least 10 percent ([TuMS § 50 lg 1^1 p 1](https://www.riigiteataja.ee/akt/129042026004)). Confirm with a local adviser: - whether an Estonian OÜ counts as subject to corporation tax without exemption for art. 119 ter; - whether the SAS and the holding owe the annual 3 percent tax on French property held by entities (CGI art. 990 D), or meet an exemption, and whether you owe the real estate wealth tax (IFI) on the property held through them. The treaty lets France tax capital in French real estate and in shares of a company whose assets consist principally of it (Art. 22(1)(a) and (b)); ask whether France treats IFI as a tax covered by the treaty in place of the former wealth tax (Art. 2(3)(a)(iv) and 2(4)); - what changes in art. 119 ter from 2027; - who bears the 5 percent duty in the sale contract. ## Who taxes the gain when I sell my company shares? France alone, while you live there. The treaty gives a gain on ordinary shares only to the seller's state of residence (Art. 13(4) of the treaty). Estonia taxes a non-resident's share gain only if the company's assets were more than 50 percent Estonian real estate at the sale or at any time in the two years before, and the seller held at least 10 percent ([TuMS § 29 lg 4 p 5](https://www.riigiteataja.ee/akt/129042026004)). EMTA confirms that other share gains are "taxed according to the tax treaty only in the resident country and are exempt in Estonia" ([EMTA](https://www.emta.ee/en/private-client/foreigner-non-resident/non-residents/gains-transfer-property)). In that land-rich case the treaty lets Estonia tax too (Art. 13(1)(b)), and France gives a credit capped at the French tax on the gain (Art. 23(1)(a)(ii)). In France, a gain on securities is taxed by default at the flat 12.8 percent, with an option for the progressive scale ([CGI art. 200 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546896)), plus 18.6 percent social contributions in 2026, of which 10.6 percent is CSG ([CSS art. L136-8](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054336623); [service-public.gouv.fr](https://www.service-public.gouv.fr/particuliers/vosdroits/F2329)). A payment from the OÜ itself on a capital reduction, a buy-back or a liquidation is different. Estonia taxes a non-resident on the part above the acquisition cost, except the part already taxed at company level ([TuMS § 29 lg 5 with § 15 lg 2 and 3](https://www.riigiteataja.ee/akt/129042026004)). The OÜ itself pays tax on the part above the contributions to its equity ([TuMS § 50 lg 2](https://www.riigiteataja.ee/akt/129042026004)). Confirm with a local adviser: the total French rate on the gain, and any holding-period allowance on shares bought before 2018 under the scale option. If you left France recently, a French exit tax on the same shares may still be deferred (see [below](https://oscaraccountant.com/en/tax-treaties/france#does-france-charge-exit-tax-if-i-move-to-estonia-and-how-does-the-deferral-end)). ## How are rent and real estate gains taxed? The state where the property is may tax the rent (Art. 6(1) of the treaty) and the gain on a sale (Art. 13(1)(a); Protocol, point 3). It may also tax a gain on shares of a company whose assets consist principally of its real estate, if its own law treats that gain like a property gain (Art. 13(1)(b)). Under the 1997 text this test has no 365-day look-back, because the MLI is not in effect for this treaty. For a French resident with an apartment in Estonia, Estonia taxes the rent and the gain of a non-resident ([TuMS § 29 lg 4 p 1, lg 6](https://www.riigiteataja.ee/akt/129042026004)). France includes the income in your return. For the rent, it gives a credit equal to the French tax on that rent, provided Estonia taxes it (Art. 23(1)(a)(i)), so in effect France does not tax it but counts it for your rate. For the gain, it gives a credit for the Estonian tax, capped at the French tax on the gain (Art. 23(1)(a)(ii)). For a French resident, rent and real estate gains bear 17.2 percent social contributions in 2026, not 18.6 percent ([service-public.gouv.fr](https://www.service-public.gouv.fr/particuliers/vosdroits/F2329)). For an Estonian resident with property in France, France taxes a non-resident's property gain at 19 percent for an individual and at the corporate rate for a company, paid through a representative accredited in France ([CGI art. 244 bis A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806274)). The same article applies to shares of a French property-rich company, and their sale bears a 5 percent duty ([CGI art. 726](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048845731)). Estonia credits the French tax (Art. 23(2)(a)). Confirm with a local adviser: the social contributions on a French property gain of a person covered by Estonian social security, and whether the main home exemption applies to a sale just after a move abroad. The dates of departure and of the deed decide it. ## Can the French CFC rule tax the profit my company keeps? It can. A French-resident individual who holds at least 10 percent of a foreign entity in a privileged tax regime is taxed each year on its profit as deemed investment income, if its assets consist principally of securities, receivables, deposits or current accounts ([CGI art. 123 bis, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000044981506)). A regime is privileged when its tax is 40 percent or more below the French tax that would be due ([CGI art. 238 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037526846)). An OÜ that keeps its profit pays no Estonian tax that year. A holding or investment OÜ usually meets the asset test, and a trading OÜ that piles up cash may meet it too. For an entity in an EU state such as Estonia, the rule does not apply unless the arrangement is an artificial scheme to get around French tax law ([CGI art. 123 bis, 4 bis](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000044981506)). Real substance in Estonia (office, staff, contracts, decisions) is the evidence. If a French company subject to corporation tax holds the OÜ, the rule is [CGI art. 209 B](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000029355796) instead. The treaty does not stop this. Art. 10(7) of the treaty protects the company's undistributed profit only against the state where the profit arises, not against France taxing its own resident shareholder. When the OÜ later pays out profit France already taxed, the treaty gives no credit for the Estonian 22/78, because that is the company's tax (Art. 23(1)(c)(ii)). At most, the two authorities can consult on double taxation the treaty does not cover (Art. 25(3)). If art. 123 bis applies and you did not declare the income, France can reassess until the end of the tenth year ([LPF art. L169](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054358875)). Confirm with a local adviser: how the 40 percent test counts the deferred Estonian distribution tax, how French law prevents a second French charge on the later dividend, the current conditions of art. 209 B, and whether French law gives any relief for the OÜ's tax. Keep a yearly breakdown of the OÜ's assets. The Estonian view of CFC rules is in our guide on [founder residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc). ## Can France tax the fees of my company as my own income under article 155 A? Yes. France taxes in the hands of a French-resident service provider the sums a foreign entity receives for his services, if he controls the entity, or cannot show that it mainly carries on another industrial or commercial activity, or if it is in a privileged tax regime ([CGI art. 155 A, I](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806359)). A one-person OÜ that only invoices its owner's work in France meets the first condition. The OÜ is jointly liable for the tax (art. 155 A, III), and when the OÜ later pays the same sums to you, the tax counts as already paid (art. 155 A, IV). The treaty does not stop this for a French resident. Your income from independent services is taxable only in France unless you have a fixed base in Estonia (Art. 14(1) of the treaty), and employment done in France is taxable in France (Art. 15(1)). The treaty protects the OÜ's profits only when it has no permanent establishment in France (Art. 7(1)). It does not settle a conflict where Estonia taxes the OÜ and France taxes you on the same income. The remedy is the mutual agreement procedure (Art. 25(3)). The same facts carry the other French risks on this page: management of the OÜ from France, a permanent establishment and an undeclared activity. Confirm with a local adviser: whether art. 155 A applies when the OÜ has staff or clients outside France, and how French courts read control and "de manière prépondérante". ## What if I never registered the activity in France? Then France can treat it as a hidden activity (activité occulte), once it shows that the OÜ or you carried on an activity taxable in France: for example a place of management in France (Art. 4(1)(a) and 4(3) of the treaty) or a permanent establishment there (Art. 5 and 7). An activity is hidden when the required returns were not filed on time and the activity was not made known to the French business registration body. The reassessment period then runs to the end of the tenth year instead of the third, also for the person who received distributions from it ([LPF art. L169](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054358875)). The penalty is 80 percent ([CGI art. 1728, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546784)). If the OÜ is resident only in Estonia and has no permanent establishment in France, France has no right to tax its profits (Art. 7(1)), and there is no French return to miss. On the text of L169 alone, Estonian registration and filings are not a notice to the French registration body. Confirm with a local adviser: whether French courts accept good-faith registration and filing in Estonia as a defence, how a voluntary disclosure changes the penalty, and whether to register a possible French permanent establishment before an audit. ## Does France charge exit tax if I move to Estonia, and how does the deferral end? Yes, if you were French tax resident for at least six of the ten years before you leave, and your holdings reach 50 percent of a company's profits or are worth more than 800,000 euros ([CGI art. 167 bis, I 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806379)). For a move to Estonia, an EU state, payment is deferred automatically (art. 167 bis, IV 1). The tax is cancelled if you still hold the shares two years after the move, or five years if your holdings exceed 2.57 million euros (art. 167 bis, VII 2). A sale or another event inside that period ends the deferral. You declare the gain in the return for the year after the move, and the deferred tax every year while the deferral runs (art. 167 bis, IX 1 and 2). The statute grants the relief ex officio (art. 167 bis, VII 2). Still, put the end date of the period in your calendar, and keep proof that you held the shares throughout (statutes, share register, registry extract). After the move, a later sale is taxed only in Estonia (Art. 13(4) of the treaty), unless the company's assets consist principally of French real estate (Art. 13(1)(b)). Estonia has no exit tax for individuals. Whether a French exit tax raises the Estonian cost of the shares is not settled ([TuMS § 38 lg 8](https://www.riigiteataja.ee/akt/129042026004)). See our guide on [founder residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc). Confirm with a local adviser: which forms and lines apply each year in your case, whether you must file to obtain the relief and with what proof, which form claims the relief at the end of the period, and the rules on a return to France. Ask before any sale, gift or buy-back of the shares inside the period. ## What if I contributed French shares to an Estonian holding? The French share-for-share rollover defers the gain on a contribution of shares to a company you control. If the holding sells the contributed shares within three years of the contribution, the deferral ends unless the holding commits to reinvest at least 70 percent of the proceeds in eligible investments within three years of the sale ([CGI art. 150-0 B ter, I 2°](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542872)). That rule applies to sales from 21.02.2026; earlier sales keep the rule of 60 percent within two years. The reporting duties of the contributor and the receiving company are set by decree (art. 150-0 B ter, VI). For the treaty, the date of the contribution decides: - **Contribution while you lived in France.** The gain arose while you were French resident, and the treaty does not stop France from taxing it when the deferral ends. - **Contribution after you became resident in Estonia.** The contribution is a sale by an Estonian resident, so the gain on shares that are not land-rich is taxable only in Estonia (Art. 13(4) of the treaty). Only the latent gain at departure stays under the French exit tax. If France taxes such a gain, use the mutual agreement procedure (Art. 25(1)). In Estonia, the holding's sale gain is taxed only when the holding distributes ([TuMS § 50 lg 1](https://www.riigiteataja.ee/akt/129042026004)). Confirm with a local adviser: which French forms you and the Estonian holding must file each year, which version of the reinvestment test applies to a sale close to 21.02.2026, and, if you contributed after the move, on what legal basis France still asks for rollover reports. ## What changes when I move to France with an existing company? From the day France becomes your residence under its law ([CGI art. 4 B](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051202565)) and, if Estonia also claims you, under the tie-breaker (Art. 4(2) of the treaty), France taxes your worldwide income. That includes dividends from the OÜ (Art. 10(1)) and a later gain on the shares (Art. 13(4)). Estonia has no exit tax for individuals. From then on: - if you run the OÜ from your French home, France may claim its place of management or a permanent establishment (see [above](https://oscaraccountant.com/en/tax-treaties/france#can-france-treat-my-estonian-company-as-a-french-company)); - the CFC rule of art. 123 bis and the reattribution of fees under art. 155 A can apply; - you declare your foreign accounts every year ([CGI art. 1649 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000045764822)). Confirm with a local adviser: what acquisition cost France uses for your OÜ shares on a later sale (historic cost or value on arrival), and whether any French arrival regime fits your case. Neither was found in the law we read. Decide before you arrive who manages the OÜ and from where, and check your social security from the first day of work in France. ## Which country taxes my pension? A pension for past employment, including the French general state scheme pension and private occupational pensions, is taxed only in the state where you live (Art. 18 of the treaty). A pension paid by a state, a local authority or a public body for government service is taxed only in the paying state (Art. 19(2)(a)), unless you are a resident and a national of the other state without being a national of the paying state (Art. 19(2)(b)). Other pension income is taxed only in the state of residence (Art. 21(1)(a)). So a French retiree who becomes Estonian resident is taxed in Estonia on French state scheme and supplementary pensions from the date of Estonian residence, while a former French civil servant's pension stays French. The Estonian rules for pensions are in our guide on [founder residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc). Confirm with a local adviser and the paying fund: whether your pension is a government-service pension or a pension for past employment, what proof of Estonian residence the fund needs to stop French withholding, how to recover tax withheld after your Estonian residence began, and whether you still file a French return. ## What must I report in France about my company and its accounts? You declare every account opened, held, used or closed abroad with your income tax return ([CGI art. 1649 A](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000045764822)), on form 3916 or 3916 bis ([impots.gouv.fr](https://www.impots.gouv.fr/international-particulier/questions/je-viens-ou-je-reviens-en-france-et-je-ne-conserve-pas-dinterets)). The fine is 1,500 euros per undeclared account, or 10,000 euros for a state with no administrative assistance agreement with France ([CGI art. 1736, IV](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373979)). Undeclared amounts can be taxed as presumed income with a 40 percent surcharge. When the declaration was missing, France can reassess until the end of the tenth year, unless the total balance of your foreign accounts never exceeded 50,000 euros in the year ([LPF art. L169](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054358875)). The OÜ shares themselves are not declared as such: their dividends and gains are. If the CFC rule applies, the OÜ's profit is declared every year. France learns about the OÜ through the treaty's exchange of information (Art. 26 of the treaty), and through the automatic exchange between EU tax authorities and under the common reporting standard, which looks through a passive OÜ to its controlling persons. Confirm with a local adviser: whether the OÜ's accounts (bank, payment institutions) count as accounts you use under art. 1649 A, and which other French declarations apply to you. ## How do I prove residence to get the treaty rates? To get the treaty rates on dividends, interest and royalties in France, an Estonian resident presents a certificate of residence form that states the nature and amount of the income and is certified by the Estonian tax authority, unless the two authorities provide otherwise (Protocol of 28.10.1997, point 14(b)). Without the proof, the French payer withholds at the domestic rate ([CGI art. 187, 1](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051218440)) and the OÜ claims a refund. Your OÜ compiles a certificate of residence in e-MTA and selects the treaty country. EMTA issues it within five working days, in Estonian, Russian or English ([EMTA](https://www.emta.ee/en/business-client/registration-business/inquiries-and-certificates/applying-certificates)). For your own Estonian income, Estonia applies treaty relief only on a residence certificate confirmed by the French tax authority ([EMTA](https://www.emta.ee/en/business-client/taxes-and-payment/income-and-social-taxes/tax-agreements)). A French company gets its certificate in its professional space on impots.gouv.fr or on form 730-SD ([service-public.gouv.fr](https://entreprendre.service-public.gouv.fr/vosdroits/F33465?lang=en)). A certificate proves residence, not beneficial ownership. For a holding, expect questions on substance. Confirm with a local adviser: which French form the French payer needs, certified by EMTA, how far ahead of the payment, and the refund deadline. ## Can France deny my company treaty benefits as abusive? Yes, even though the treaty has no principal purpose test in force. The reduced rates on dividends, interest and royalties go only to the beneficial owner (Art. 10(2), 11(2) and 12(2) of the treaty), so a holding OÜ that only passes income on risks losing them. France also has domestic anti-abuse rules: - the exemption for EU parent companies does not apply to an arrangement that is not genuine and has a tax advantage as a main purpose ([CGI art. 119 ter, 3](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000031815505)). The treaty rate then still caps the withholding, if the OÜ is the beneficial owner; - the EU exception of the CFC rule does not cover an artificial arrangement ([CGI art. 123 bis, 4 bis](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000044981506)). Once the MLI takes effect for this treaty, it will add a principal purpose test (MLI Art. 7(1)) and a preamble against treaty shopping (MLI Art. 6(1)). Document the business reasons and the substance of the OÜ before you claim French treaty relief. Confirm with a local adviser: what changes in art. 119 ter from 2027, and the French case law on single-asset holdings. ## What can I do if both countries tax the same income? You can start a mutual agreement procedure. You present the case to the tax authority of your state of residence within three years from the first notice of the action that taxes you against the treaty, whatever domestic remedies you use (Art. 25(1) of the treaty). An agreement is carried out whatever the domestic time limits (Art. 25(2)). The authorities can also settle questions of interpretation and consult on double taxation in cases the treaty does not cover (Art. 25(3)). This matters for the Estonian distribution tax and for a company both states claim as resident. EMTA lists what to send: the identification data of the taxpayer and any related taxpayer, copies of the assessments, the treaty articles concerned, the steps already taken and a proposed solution ([EMTA](https://www.emta.ee/en/business-client/taxes-and-payment/income-and-social-taxes/tax-agreements)). The treaty has no arbitration. Between the two EU states, [Council Directive (EU) 2017/1852](https://eur-lex.europa.eu/eli/dir/2017/1852/oj) offers an EU dispute procedure as well. Once the MLI takes effect, you could present the case to either state's authority (MLI Art. 16), with the same three-year limit. Count the three years from the first notice of the assessment, not from a final court decision. VAT is outside the treaty, so no mutual agreement procedure applies to it. Confirm with a local adviser: how to protect your French appeal deadlines while the procedure runs, and whether the EU procedure fits your case better. ## What did the most-favoured-nation clause change in 2015? Royalties and bank interest changed. Dividends did not. The Protocol imports automatically any better treatment Estonia later agrees with a state that was an OECD member on 28.10.1997 (Protocol, points 9 and 10). The Estonia - Luxembourg convention, in force from 11.12.2015, triggered it: - **Royalties** are taxable only in the state of residence of the beneficial owner, and equipment rental is no longer a royalty (Protocol, point 10). The French administration also drops films and recordings for television or radio from the definition. - **Interest** on a loan of any kind granted by a credit institution is taxable only in the state of residence (Protocol, point 9). An earlier trigger, from 21.05.2006, had done this for bank loans to enterprises. Other interest keeps the 10 percent source limit (Art. 11(2) of the treaty), on the French reading. - **Dividends** keep the 5 and 15 percent limits (Art. 10(2)). The Protocol has no such clause for dividends. The two administrations describe the interest change differently. The Estonian Ministry of Finance speaks of exclusive residence taxation of interest ([Ministry of Finance](https://www.fin.ee/en/public-finances-and-taxes/tax-and-customs-policy/overview-estonian-bilateral-conventions-avoidance)), and the French consolidated version adds only interest from credit institutions ([impots.gouv.fr](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_version_consolidee_npf.pdf)). Neither consolidated text is authentic. Confirm with a local adviser: which reading France applies to non-bank interest, such as a shareholder or group loan, before you rely on an exemption. ## Does the MLI change this treaty? Not yet. Both states list the treaty as covered, but the MLI is not in effect for it, because Estonia made its effect depend on a notification under MLI Art. 35(7)(b) that it has not sent for France. No synthesised text exists. This is the status on 15.09.2026 ([OECD status list](https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf)). On the current positions, once in effect: - MLI Art. 6(1) would add a preamble against non-taxation and treaty shopping; - MLI Art. 7(1) would add a principal purpose test; - MLI Art. 9(4) would replace Art. 13(1)(b) of the treaty: a 365-day test and more than 50 percent of the value from real estate; - MLI Art. 16 would let you present a mutual agreement case to either state. The MLI would not change the residence rule for companies (Art. 4(3)) or the permanent establishment rules (Art. 5). After Estonia's notification, the MLI would apply to taxes withheld at source from 1 January of the year after the date 30 days after the notification, and to other taxes for taxable periods beginning six months or more after that date (for Estonian taxes, from 1 January of the following year). Some advisers already apply the MLI land-rich test to this treaty. That is not correct as of 01.10.2026. Check the OECD status list for an Estonian notification for France before you rely on the 1997 text of Art. 13(1)(b) and 25(1) for a later year. General information, not advice for your situation. The law as in force on 01.10.2026. ## Let Oscar do the work Oscar books your dividends and files the salary tax declaration (TSD) for you. [Join waitlist](https://oscaraccountant.com) ## Sources - [Estonia - France tax treaty (1997), Riigi Teataja](https://www.riigiteataja.ee/akt/78860) - [Estonia - France tax treaty, French text (impots.gouv.fr)](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_convention-avec-l-estonie_fd_1428.pdf) - [Estonia - France tax treaty, consolidated version after the most-favoured-nation clauses (impots.gouv.fr, not authentic)](https://www.impots.gouv.fr/sites/default/files/media/10_conventions/estonie/estonie_version_consolidee_npf.pdf) - [impots.gouv.fr, treaty page for Estonia](https://www.impots.gouv.fr/estonie) - [Ministry of Finance, overview of Estonia's tax treaties](https://www.fin.ee/en/public-finances-and-taxes/tax-and-customs-policy/overview-estonian-bilateral-conventions-avoidance) - [OECD, MLI signatories and parties](https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf) - [Income Tax Act (TuMS)](https://www.riigiteataja.ee/akt/129042026004) - [Social Tax Act (SMS)](https://www.riigiteataja.ee/akt/121052026019) - [Commercial Code (ÄS)](https://www.riigiteataja.ee/akt/106072023131) - [EMTA, Tax liabilities of companies (non-residents and e-residents)](https://www.emta.ee/en/business-client/registration-business/non-residents-e-residents/tax-liabilities-companies) - [EMTA, Tax agreements](https://www.emta.ee/en/business-client/taxes-and-payment/income-and-social-taxes/tax-agreements) - [EMTA, Gains from transfer of property (non-residents)](https://www.emta.ee/en/private-client/foreigner-non-resident/non-residents/gains-transfer-property) - [EMTA, Applying for certificates](https://www.emta.ee/en/business-client/registration-business/inquiries-and-certificates/applying-certificates) - [CGI art. 4 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000006302200) - [CGI art. 4 B, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051202565) - [CGI art. 111, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000043662702) - [CGI art. 117 quater, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000036428175) - [CGI art. 119 bis, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051218411) - [CGI art. 119 ter, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000031815505) - [CGI art. 123 bis, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000044981506) - [CGI art. 125 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037526745) - [CGI art. 150-0 B ter, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542872) - [CGI art. 155 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806359) - [CGI art. 158, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373673) - [CGI art. 167 bis, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806379) - [CGI art. 182 B, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000045765660) - [CGI art. 187, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051218440) - [CGI art. 200 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546896) - [CGI art. 209, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048847486) - [CGI art. 209 B (version of 01.01.2015), Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000029355796) - [CGI art. 219, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542939) - [CGI art. 238 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037526846) - [CGI art. 244 bis A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806274) - [CGI art. 726, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048845731) - [CGI art. 1649 A, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000045764822) - [CGI art. 1728, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053546784) - [CGI art. 1736, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054373979) - [LPF art. L169, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054358875) - [Code de la sécurité sociale art. L136-8, Legifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000054336623) - [service-public.gouv.fr, social contributions on investment income](https://www.service-public.gouv.fr/particuliers/vosdroits/F2329) - [service-public.gouv.fr, certificate of tax residence for professionals](https://entreprendre.service-public.gouv.fr/vosdroits/F33465?lang=en) - [impots.gouv.fr, declaring foreign accounts on arrival in France](https://www.impots.gouv.fr/international-particulier/questions/je-viens-ou-je-reviens-en-france-et-je-ne-conserve-pas-dinterets) - [CLEISS, self-employed activity in France by a person insured in Estonia](https://www.cleiss.fr/independants/etranger_france883.php?from=estonie&nat=france) - [Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms, EUR-Lex](https://eur-lex.europa.eu/eli/dir/2017/1852/oj) - [Regulation (EC) No 883/2004, EUR-Lex](https://eur-lex.europa.eu/eli/reg/2004/883/oj) - [Regulation (EC) No 987/2009, EUR-Lex](https://eur-lex.europa.eu/eli/reg/2009/987/oj) ## Related pages - [The founder abroad: tax residency, permanent establishment and CFC rules](https://oscaraccountant.com/en/guides/founder-residency-pe-cfc): How Estonia decides tax residency, when a home office abroad creates a permanent establishment, and how your home country can tax your OÜ. - [Corporate income tax in Estonia: tax on distributed profit](https://oscaraccountant.com/en/guides/cit-distribution-tax): How Estonia taxes company profit only when it is paid out: the 22/78 rate in 2026, how to compute it, losses, non-resident owners, and salary versus dividend. - [Paying a dividend from an Estonian OÜ: the steps, the limits and the TSD](https://oscaraccountant.com/en/guides/dividends-mechanics): The steps to pay a lawful dividend from an OÜ, how much you may pay, instalments, dividends in kind, and how to declare it on the TSD. - [Paying yourself as the founder of an Estonian OÜ: board fee, salary and social tax](https://oscaraccountant.com/en/guides/founder-remuneration): How the owner-manager of an Estonian OÜ is paid: the board member fee, a salary, the minimum social tax, health insurance, the basic exemption and the TSD. - [Contractors, freelancers and staff abroad: a guide for Estonian companies](https://oscaraccountant.com/en/guides/contractors-and-cross-border-workers): When an Estonian OÜ can pay a contractor instead of an employee, what it withholds for freelancers abroad, how the A1 certificate works, and the tax of an FIE invoice. - [Estonian dividend tax calculator](https://oscaraccountant.com/en/tools/dividend-tax-calculator): Work out the corporate income tax on a dividend from an Estonian company, from the net or the total amount, with the rate of the payment date and the TSD due date. - [OÜ (osaühing)](https://oscaraccountant.com/en/glossary/ou): What an OÜ (osaühing) is: the Estonian private limited company, with shares, limited liability, a share capital from one cent and a management board. - [Social tax (sotsiaalmaks)](https://oscaraccountant.com/en/glossary/social-tax): What sotsiaalmaks is: the 33 percent tax an Estonian employer pays on top of pay, the 2026 minimum base of 886 euros, and how it funds health insurance and pension. Reviewed on 10 Oct 2026. Law as of 1 Oct 2026. General information, not advice for your situation. --- - [For AI agents](https://oscaraccountant.com/agents) - [Learn](https://oscaraccountant.com/en/learn) - [Guides](https://oscaraccountant.com/en/guides) - [Tools](https://oscaraccountant.com/en/tools) - [Tax treaties](https://oscaraccountant.com/en/tax-treaties) - [Privacy policy](https://oscaraccountant.com/privacy) - [Terms of use](https://oscaraccountant.com/terms) - [Partner program](https://oscaraccountant.com/en/partners) OscarAI OÜ · Registry code 17608438